This case involved various claims arising from the death of SGT, a minor and former student at St. Marys Middle School in the Camden County School District. Plaintiffs alleged SGT died of suicide because of multiple bullying incidents at the school and Defendants’ failures to adequately respond to and address those incidents and asserted claims under the Americans with Disabilities Act (“ADA”) and Georgia law.
Plaintiffs retained a psychology expert, Dr. Sheila Crowell, to opine on the causal chain of stressors leading to SGT’s suicide and SGT’s symptoms of ADHD. In her report, Crowell opined SGT experienced stress as a result of actions and inactions by staff at St. Marys Middle School and the cumulative nature of these stressors exceeded the typical level of stress most children encounter.
Crowell opined there was a clear precipitating event for SGT’s suicide on November 18, 2019. SGT made “origami rockets” for a classmate on November 15, 2019. The classmate threw the origami rockets in the math classroom, and one got stuck in the ceiling. On November 18, 2019, Jackson sent SGT to the “ownership room” for this incident.
Crowell opined this event appeared to have been on the forefront of SGT’s mind on the day he died by suicide. In Crowell’s deposition, she detailed a process called “chain analysis.” “A chain analysis is where you go through the chain of events that led to a person harming themselves.”
Defendants argued Crowell formed her opinions based on information that was narrowly focused on stressors SGT experienced at school, and Crowell did not sufficiently consider stressors outside the school. Defendants asked the Court to exclude Crowell’s opinions.
Psychology Expert Witness
Sheila Crowell is a tenured Psychology Professor at the University of Utah. She has been a licensed and practicing psychologist since 2013. Crowell has received funding from the American Foundation for Suicide Prevention and the National Institutes of Health to better understand and prevent suicide. Crowell has produced 115 peer-reviewed and invited publications, of which 30 publications deal directly with the topic of suicide or self-injury.
Discussion by the Court
Crowell’s Opinions Are Based on Reliable Methodology
Defendants argued Crowell’s methodology was not reliable for two reasons. First, Defendants contended Crowell’s opinions are based solely on deposition testimony that was narrowly focused on stressors SGT may have encountered at school. Defendants argued SGT could have encountered other stressors, including discipline at home, interactions with peers outside of school, and SGT’s relationship with his parents, but Crowell did not consider these additional stressors in forming her opinions. Second, Defendants argued Crowell’s “chain analysis” was merely her subjective opinion.
Crowell’s opinions are based solely on deposition testimony that was narrowly focused on stressors SGT may have encountered at school
Crowell’s report and deposition testimony demonstrated that she reviewed numerous documents to determine which stressors contributed to SGT’s suicide. In addition to depositions from school administrators, Crowell considered SGT’s suicide note, SGT’s suicide video, an interview with SGT’s brother, and Plaintiff Kohn’s deposition.
Crowell’s report and testimony showed that although she considered information about other stressors from outside of school, like SGT’s home life and parental discipline, she determined those stressors were not “proximal stressors” on the day of SGT’s suicide.
The Court did not find that Defendants have shown Crowell’s opinions were improperly based on insufficient information.
Crowell’s “chain analysis” was merely her subjective opinion
The Court held that the Defendants’ second challenge regarding the reliability of Crowell’s chain analysis methodology is also unconvincing.
Crowell has sufficiently explained the connection between her training and experience and her opinion that actions and inactions by staff at St. Marys Middle School likely increased SGT’s vulnerability to mental health struggles and led to SGT’s suicide. Defendants have not shown Crowell’s chain analysis is based on an unreliable methodology.
Crowell relied on her training and experience as a clinical and research psychologist when she performed a chain analysis in this case. Crowell identified several documents she reviewed related to this case, including depositions, a forensic interview, and an academic article focused on youth suicide. After reviewing those materials, Crowell noted there was no evidence of any mental health support for SGT or any efforts to protect him from bullying.
Crowell’s Opinions Will Assist the Trier of Fact
Defendants argued causation is the “[t]he legal issue” in this case, and Crowell’s opinions would not assist the trier of fact in resolving that issue. According to the Defendants, Crowell’s opinions focused only on what happened immediately before the suicide, not long-term stressors, and, therefore, her opinions will not help the jury determine whether and to what extent other events could have contributed to SGT’s death.
Defendants’ contention that Crowell’s opinions will not assist the trier of fact is unconvincing. The Court held that Crowell’s opinions concern the relevant time period for assessing causal factors leading up to a suicide and self-harm generally, and, specifically, concern the proximal stressors that may have contributed to SGT’s suicide. Crowell’s opinions on these topics arise from her specialized training and experience in psychology and assessing risk of self-harm and suicide (with special focus on risks for adolescents). Crowell’s opinions concern a core issue in this case—the cause of SGT’s suicide—and the opinions concern topics likely beyond the understanding of the lay person.
Held
The Court denied the Defendants’ motion to exclude the testimony of Sheila Crowell.
Key Takeaway:
- Crowell identified the “ownership room” incident as a clear precipitating event for SGT’s suicide, particularly because the “ownership room” probably had negative historical meaning for SGT. Crowell noted the “ownership room” incident occurred in the context of ongoing academic struggles.
- Crowell’s opinions concern a core issue in this case—the cause of SGT’s suicide—and the opinions concern topics likely beyond the understanding of the lay person. Therefore, Crowell’s opinions would be helpful to the trier of fact.
Case Details:
| Case Caption: | Kohn Et Al V. Camden County School District Et Al |
| Docket Number: | 2:21cv108 |
| Court: | United States District Court, Georgia Southern |
| Order Date: | August 21, 2024 |
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